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Third Party Verification Requests The Letter of Comfort. What can the CPA provide?. Name of presenter Audience Date. Today’s Agenda. Professional Services/ Additional Procedures Advisory/ consulting services Agreed-Upon Procedures Attest engagements and Levels of Assurance FAQs Summary
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Third Party Verification RequestsThe Letter of Comfort What can the CPA provide? Name of presenter Audience Date
Today’s Agenda • Professional Services/ Additional Procedures • Advisory/ consulting services • Agreed-Upon Procedures • Attest engagements and Levels of Assurance • FAQs • Summary • Questions? • Overview • Common Verification Requests • Responding to Requests • What can the CPA provide? • What can’t the CPA provide?
Seeing an Increase in Requests • Not a new issue • For banks • Continued tightening of credit underwriting standards • For individual and businesses • As economy improves more individuals and business owners are seeking funding • Increase in diversity of: • Purpose • Nature • Scope • Intent • Small business owners are impacted the most
Examples of Borrower Information Requested • Confirmation of a client’s self-employment status • Verification of income from self-employment • Verification of a borrower’s business ownership percentage • Profitability or sustainability of a self-employed client’s business • The impact on a self-employed client’s business if money is withdrawn to fund the down payment on a real estate purchase • Validation of certain information presented on a tax return
CPAs Asked to Validate Information By Providing: • A confirmation letter containing specific language • A verification statement validating certain information presented on the tax return • Certain information on a form
CPAs Cannot Provide • Assurance on matters relating to SOLVENCY • Confidential client information without client approval • Client tax information without signed, written consent in IRS-specified format • Certification or validation to a third party about information reported on a tax return without performing additional procedures. ALERT: For a CPA to validate information reported on a tax return without performing additional procedures would constitute a violation of professional standards, resulting in licensure implications for the CPA
Understanding Lender Needs • What level of assurance is really needed: • Factual information –OR– • CPA validation or certification of information (often requiring additional procedures performed by the CPA) • If additional procedures are necessary, take into consideration: • The associated time and • Additional costs to the borrower • Professional services that comprise additional procedures include: • Advisory/consulting services • Agreed-Upon Procedures • Attest engagements
Advisory/ Consulting Services • CPAs can provide factual information (with client consent) • CPAs use professional judgment to obtain the necessary factual information as long as they aren’t verifying or validating information without performing necessary additional procedures • CPAs can prepare financial projections • For requests asking pending loan’s impact on borrowers self-employed business • CPAs cannot provide assurance to a client’s ability to repay the loan
Agreed-Upon Procedures Engagement • CPAs can prepare a report of findings based on specific procedures performed on specified subject matter • This subject matter and related procedures must be clearly defined and relatively limited in scope • Subject matter may take many different forms and may be as of a specified date or over a specified period • CPA does not provide an opinion or negative assurance
Attest Engagements: The Compilation • Most basic level of service • CPA assists management in presenting financial information • Does not contemplate performing inquiry, analytical procedures, or other procedures • No assurance that there are no material modifications that should be made to the financial statements • The report states that no assurance is provided
Attest Engagements: The Review • Involves primarily analytical procedures and inquiries that will provide a reasonable basis for obtaining limited assurance • A review does not assess internal control, fraud risk • A review does not test accounting records or other procedures • The report provides a statement that the accountant is not aware of any material modifications that should be made to the financial statements
Attest Engagements: The Audit • Auditor is required to obtain an understanding of the entity’s internal control and assess fraud risk • Obtain audit evidence • Inquiry, physical inspection, observation, third party confirmations, examination, analytical and other procedures • The auditor’s report provides an opinion as to whether the financial statements present fairly, in all material respects, the Company’s financial position, results of operations and cash flows
Self-Employment • Question: • Can the CPA confirm a borrower’s income from self-employment or self-employment status? • Response: • The CPA can only provide factual information, such as copies of tax returns (with signed written consents from the client) • The CPA can provide a letter verifying they prepared the tax return based on information the client provided • This letter can be provided along with tax return copies • The CPA cannot verify or validate the information reported on a tax return without performing additional procedures
Financial Projection of Business Income • Question: • Can a CPA provide a requestor with a financial projection of business income over a specified period? • Response: • A CPA can perform a financial forecast for a client and report their findings (with client consent). • A CPA cannot attest to the sustainability of the client’s business as a result of that forecasted projection (that would be expressing an opinion on a client’s solvency).
Knowledge of Information Requested • Question: • Can a CPA just respond to a request if he has knowledge of the information requested? • Response: Yes • A CPA can respond to a form letter or email provided that the information is: • Factual information • Not expressing an opinion unless attestation performed • Not providing an attestation on solvency
In Conclusion… • Credit decisions are based on a lender’s exercise of due diligence • This includes considering multiple factors and information • The burden of determining the impact on the ability of the business to continue operating as a result of the withdrawal is solely on the lender or broker • A CPA cannot provide assurance on any matter related to a client’s ability to repay the loan • Options are available to meet lender/borrower’s needs • Working as a team, the lender, the CPA and the borrower can determine how to best meet everyone’s needs